MR. THOMPSON: Good afternoon, everybody. Good
afternoon, distinguished Board members. My name is
. I'm the executive vice president of
the International Council of Cruise Lines. I too am
a retired Coast Guard officer, having spent my
entire career in marine safety, security and
environmental protection.
I appreciate the opportunity here today to be here to discuss these issues. I would like to thank the Board for the extraordinary effort to participate in the educational sessions in Alaska on board the Island Princess. I want to digress for a moment and say that the International Council of Cruise Lines is a trade association that represents 16 of the largest cruise vessel operators in the North American market. Our members operate approximately 120 ships and this year will carry in the neighborhood of million passengers. I would like to also say to Laurie that I hope it was not an ICCL member that gave you the wrong information. I apologize if it was. At the very least you should get the appropriate information as to what the accessibility of our existing vessels is.
I would like to thank the Board, as I said, for the extraordinary effort to participate in the educational session aboard the Island Princess. We believe it was very beneficial. We discussed a number of topics including tender vessel access, tender vessel operations, the on/off issue, various vessel construction issues such as weather-tight doors and sills versus hard closure.
This is a sill in this area. This is a hard-closure perpendicular, another type sill that actually prevents the water from coming in. We also talked about things like deck camber. Deck camber the transverse tilting, if you will, the slope of the deck to aid in shedding of water from ocean spray or rains or whatever. What I would like to do today is discuss three or four policy issues that we believe are apparent, and my colleague, Jeff Frier, will discuss some of the specific issues that we were asked to identify by Board members who were on the trip.
I'm sure many of you would be disappointed if I did not repeat my mantra, so I will. Ships are not buildings. Ships are more than buildings. Buildings do not encounter extreme forces in heavy seas. Buildings do not encounter motion and acceleration in 6 degrees of freedom, rule, pitch, heave, surge, sway and yaw. I thought about leaving that up for the entire discussion that we were having and maybe we could get people to see what it might be like on a ship in heavy seaway. But all of these things are taken into account in the design of the ship, the integrity of the hull and the systems, including safety systems, must incorporate this extreme motion. We try to avoid the type of weather you see here, but there are instances when we are not able to.
Ships are built as an integral system and they comply with extensive and complex rules for safety and operational procedures. These rules are determined by the International Maritime Organization, vessel classification societies, flag states, and even the United States Coast Guard for non U.S.-flagged cruise ships. These rules address not only construction such as overall strength, but also complex safety systems, such as fire detection systems that are monitored and supervised. They also address operational procedures such as crew firefighting response, the possibility of having to abandon ship, the requirement for passengers to be drilled in emergency procedures, which does not happen ashore or in a shore-side environment.
Likewise, in an emergency shore hotel staff or building staff are expected to evacuate along with the guests to await emergency response. On a ship, crew training is extensive. In an emergency, ship's crew is fully trained to assist each passenger and to search each cabin and space to assure that everyone is accounted for and that no one, absolutely no one is left behind. The crew is trained and tested in knowledge, understanding and proficiency in their assigned duties, and each crew member has an assigned duty in an emergency.
These crew members are examined frequently by the United States Coast Guard and their ability to carry out their duties. So Point Number 1 that we would like to make is that any regulations or guidelines should recognize and incorporate the operational aspects of carrying passengers on board a ship, and that crew training and crew assistance/response should be recognized as absolutely essential and taken into account.
Cruise ships are designed and built to withstand extreme weather conditions. They have the most modern technologies to operate at sea, even in the event of a rogue wave. I'm sure you have all heard about the wave that hit one of our member's vessels back in early April. That ship was approximately the same size as this ship, and that wave that you see there is approximately a 70-foot wave, and it's almost an identical situation.
This ship did not suffer any damage. The damage to the previous ship was not due to the wave itself, but a railing that was not properly welded was torn off and thrown into a window.
Point 2, we believe that the use of new and future technologies should not be limited or prevented by prescriptive requirements. As an example, we believe that the use of portable communications assistance kits, e-mail and hand-held devices and other future developments of communication are certainly a wave of the future, if you will. We believe they provide an extreme diversity, if you will, of accessibility that you can use in any space on board a ship rather than being limited to certain prescriptive requirements and individual spaces.
On/off has been discussed a little bit today. On board cruise ships, there are a number of different ways to get on and off. In major ports where we have terminals and passenger bridgeways to the ships, such as this one -- this is in New Orleans. You can actually see the bridgeway along here. From the terminal this is that bridgeway. Very similar to what you would find in an airline terminal.
From there we go to tendering vessels that use the ports, vessels to carry the passengers back and forth that may or may not match up to the ship, may or may not match up to the port facilities themselves.
We also have opportunity to use the vessels, tendering boats. This is a rather new ship. It has a side tendering port and the ship's tendering vessel comes up alongside.
We provide an accessible path in most instances, at least on the newer ships, to the tendering port. From the tendering port onto the tender, you can see this one has a bit of a gap between the tendering port and the vessel itself. In many instances that can be minimized by persons standing on the tendering vessel. But because of the motion between the tendering vessel and the ship, which is almost always present, it will take assistance to get the chairs on board.
But you can see, at least in this case and in the previous slides that I showed, the first two slides in the presentation, that many of the tendering vessels are now being built to be accessible for wheelchairs.
If the sea is rough, and there are certain areas in Hawaii where it tends to be like that a considerable amount of the time, the virtual motion between the ship and the tendering vessel renders it almost impossible to get a chair on board. In many instances it's very difficult for anybody to get on board, and in some instances the master will cancel port call because of the roughness of the sea.
Once you're on board the tender, then you have to interface with the port facility. Here it's not too bad. In other instances it's not quite as good.
Some of the facilities that we call at have limited infrastructure, limited size of the dock that we are able to call at.
Here you see in Stewart, Alaska, that has a tidal range of about 17 feet. In one instance the ramps are a very steep slope. A couple hours later you see the side port becoming available here as the tide rises. As soon as that side of the port becomes available, the gangway can be lowered and the ramp slope becomes a lot less.
So that brings us to Point 3 that I would like to make. In many instances one rule or guideline requirement will not fit all circumstances either with regard to the ship-port interface or the ship-port arrangement itself. Rules should be flexible and, if possible, performance oriented to meet these widely varying circumstances from port to port and ship to ship.
Ladies and gentlemen, the cruise industry fully supports the development of feasible access guidelines within the constraints of regulatory framework that has been developed for operations in a great environment. The Volpe (phonetic) study itself stated that these arrangements must be a pragmatic approach to innovative solutions.
Port members on the Alaska trip can attest that the Island Princess is extremely accessible. That doesn't mean that it won't be better in the future. We believe that accessibility on cruise ships is improving with each new design and each new ship. And this has been done without regulations. We hope that the regulatory process will enhance our ability to provide a safe, secure, accessible vacation experience to all of our guests. This is who I am. If you have any questions either now or in the future, don't hesitate to contact me. My colleague, Jeff Frier, will present some specific points with regards to the proposed guidelines. I would be happy to answer any questions.
MR. [GARY] TALBOT [BOARD MEMBER]: Thank you very much, Ted. Any of the members have any questions?
MS. [PAMELA] DORWARTH [BOARD MEMBER]: Where did you say you were retired from?
MR. THOMPSON: United States Coast Guard.
MS. DORWARTH: It wasn't the Navy. I'm sorry.
MR. THOMPSON: If you remember what Pete said, my biography parallels his, about ten years later. He's an old guy.
MS. DORWARTH: It was not the Navy. So we'll tell the PVA, I'm sorry. I got the wrong branch.
MR. [PHILIP] PEARCE [BOARD MEMBER]: I have a question that relates to your Point Number 2. You had suggested, I think, and correct me if I am wrong, that you were concerned that rules would be limiting on your ability to implement future technologies or actually improve accessibility; is that correct?
MR. THOMPSON: Yes, sir.
MR. PEARCE: What in the rule gave you the impression that our rule would ever limit your ability to use technology that would actually create greater accessibility? Because we need to create that because most of our rules specifically say that if you have technology or capacity to have better accessibility than what we specify in the rules, then we encourage you to use those newer technologies.
MR. THOMPSON: The example I gave, the portable communications, we're concerned with what we believe is an excessive requirement for TTY kits. If you read it, there are literally probably almost a thousand TTY locations that would be required. We have portable kits and there's technology available such as hand-held devices, Blackberries that will allow text paging, text messaging that we believe could be -- and the portable communication assistance kits that could be set up in any stateroom on board the ship, thus allowing that type of accessibility in any stateroom instead of just the hard-wired staterooms. We can understand the need for some, but we think the current requirement is being overtaken by technology. And we're under the impression by some of the feedback we received that that may not be a proper substitution. We're going to try to show we think it is.
MR. TALBOT: Any other questions?
MR. [JAMES] ELEKES [BOARD MEMBER]: Yes, one question. The industry seems to be based, is based I presume, on customer service customer sensitivity. With the increases in oil prices and the impact, adverse impact, it's having on the cruise industry, to maintain your profit margins and such, is it likely that the level of customer service, customer assistance that is available to individuals with disabilities could potentially lessen because of cutbacks in staffing in order to maintain a profit-type margin?
MR. THOMPSON: Let me answer that from two aspects. First of all, the increase in oil prices does not have as great an effect on the cruise industry as, say, on the airline industry. My understanding, and maybe there are some of our members here that can be a bit more specific, but my understanding is that the cost of the fuel represents 3 to 4 percent of the cruise cost basis or the expenses for the cruise industry; as opposed to the airline industry where the cost of the fuel is whatever, 30, 40, 50 percent. So there's a much greater impact on an airline industry or bus industry or something where the cost of the fuel has a much -- is a greater part of the base. With regards to cutback of staff, there's a thing called the Safe Manning Certificate that is required of ships, and that will not be cut back. If you want to carry those passengers, you have to have that safe manning on board.
With regards to crew members that may not be on the Safe Manning Certificate, but who also have safety functions in an emergency, those crew members are not assigned to assist and to serve only those passengers with special needs but for everybody. It is unlikely that we're going to cut back on those types of services that will decrease the guest experience and thus make cruising less attractive as a vacation option.
As with everything, there is always a possibility of raising the price to cover the fuel surcharge or whatever, but in terms of cutting back services because of that, I find it extremely unlikely. Thank you.
MR. [DOUGLAS] ANDERSON [BOARD MEMBER]: Who's regulates the Safe Manning Certificate? Is that through the Coast Guard?
MR. THOMPSON: That's through the International Maritime Organization and the flag state of the ship and it's usually reviewed very closely by the United States Coast Guard, who also reviews our plans at the inception stage, inspects our ships during construction and examines the ships and crew four times a year thereafter.
MR. TALBOT: Thank you very much.